Best practice guidance on monitoring equality and diversity in employment

March 2012

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Contents

1 Introduction ............................................................................................ 3

2 What is workforce monitoring and why should we be doing it? .............. 5

3 What should we monitor? ...................................................................... 6

4 What questions should we ask? ............................................................... 7

5 Preparing the organisation for monitoring ............................................ 17

6 Use of diversity data ............................................................................ 20

Annex A – Sample Equal Opportunities Monitoring Form ........................................ 22

Annex B - NATIONALITY CODES (as used by the UK Border Agency) .................. 24

This guide has been developed by the Cross-Government Heads of Equality Group, which aims to build the capability of departments and agencies to improve the coverage, quality and consistency of their diversity data. The group helps to meet the requirements of the Civil Service Diversity Strategy, ―Promoting Equality, Valuing Diversity‟.

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1 Introduction

1.1 This guide provides practical advice for departments and agencies that want to improve their equality and diversity monitoring. It specifically covers the collection of personal data which will be identifiable to the individual. 1.2 Whilst this does not mandate every department to collect all the information/ categories included, the purpose of this guide is to provide a framework to move towards over time and that allows departments to collect comparable data. It also reflects best practice, thereby reducing the need for each department to consult and agree their own categories. It will be for each department to decide for themselves the best process for them to comply with legislative monitoring arrangements, so for example, some may collect some of the information by an employee self-service facility (which may have markers for those who are pregnant or on maternity leave), whereas in other scenarios such as recruitment or training, departments may wish to use manual forms. 1.3 Wherever and whenever possible departments and agencies should use the standardised questions within this guide, which reflect or could be aggregated to those categories used in the 2011 Census. Departures from these categories may be necessary where there are key operational or business concerns, or issues that need to be addressed that require deviation from this question set, or additional supplementary questions.

1.4 This guidance covers:

The benefits of monitoring;

The groundwork that needs to be put in place;

What we should monitor; and

The questions that we should ask. 1.5 Effective monitoring is a legal requirement for the civil service under the Equality Act 2010, which sets out public sector equality duty in relation to the following protected characteristics:

Age

Disability

Gender reassignment

Marriage/civil partnership status

Pregnancy and maternity

Race – this includes ethnic or national origins, colour or nationality

Religion or belief – this includes lack of belief

Sex

Sexual orientation

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1.6 Section 149 of the Equality Act 2010 sets out the public sector equality duty and

states that

149 (1)A public authority must, in the exercise of its functions, have due regard to the need to—

(a)eliminate discrimination, harassment, victimisation and any other conduct that is prohibited by or under this

Act;

(b)advance equality of opportunity between persons who share a relevant protected characteristic and

persons who do not share it;

(c)foster good relations between persons who share a relevant protected characteristic and persons who do

not share it.

(2)A person who is not a public authority but who exercises public functions must, in the exercise of those

functions, have due regard to the matters mentioned in subsection (1).

(3)Having due regard to the need to advance equality of opportunity between persons who share a relevant

protected characteristic and persons who do not share it involves having due regard, in particular, to the need

to—

(a)remove or minimise disadvantages suffered by persons who share a relevant protected characteristic that

are connected to that characteristic;

(b)take steps to meet the needs of persons who share a relevant protected characteristic that are different

from the needs of persons who do not share it;

(c)encourage persons who share a relevant protected characteristic to participate in public life or in any other

activity in which participation by such persons is disproportionately low.

1.8 It also applies to marriage and civil partnership, but only in respect of the requirement to have due regard to the need to eliminate discrimination. 1.9 Effective monitoring is an important tool for measuring performance and progress towards equality and diversity goals and in ensuring a truly inclusive working environment. Monitoring is not an end in itself. Data that is collected needs to be analysed and used to inform appropriate action.

1.10 Monitoring will only generate meaningful and reliable results when employees feel safe and confident in disclosing personal information and when they feel assured that meaningful action will follow. Departments who have been successful in doing this have taken significant steps to reassure staff on issues of confidentiality through their communications.

1.11 A sample equal opportunities monitoring form is attached at Annex A. This would have to be amended accordingly for staff in Northern Ireland and Scotland.

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2 What is workforce monitoring and why should we be doing it?

What is monitoring? 2.1 Monitoring equality and diversity in the workforce enables departments and agencies

to examine how their employment policies and processes are working and to identify areas where these appear to be impacting disproportionately on certain groups of staff. It is necessary to meet legislative requirements, provide the basis for showing ‘due regard’ and can lead to the development of better and more informed, inclusive decision making, including decisions on recruitment and promotion. Effective monitoring also helps departments minimise possible legal, financial and reputational harm.

2.2 Monitoring can be done at a variety of different points in the employment cycle including recruitment, training, promotion, staff surveys, performance management, grievances and dismissals. The purpose of collecting this information is to look for differences between groups, identify trends over periods of time, to investigate the reasons for these differences and to put suitable actions in place.

Benefits for departments and agencies 2.3 Understanding the composition of the workforce can enable an organisation to

highlight differences between groups in terms of satisfaction, engagement and progression. This in turns can enable organisations to identify, tackle and prevent issues that would otherwise undermine employee engagement and productivity.

2.4 Equality and diversity monitoring can help to:

build reputation – Research shows that the best performing organisations are those that invest most on promoting equality and diversity in their workforce

1;

improve productivity – We know that valuing and supporting the diversity of people‟s backgrounds and lifestyles is important in making the most of the contribution that they can bring to an organisation’s performance

2;

recruit and retain the best from the widest talent pool;

create awareness - Signalling the organisation’s understanding of and commitment to creating a more inclusive work environment;

provide specific adjustments, training or interventions;

Identify and address any inequalities - in the application of employment practices; and

avoid risk –compliance with the Equality Act 2010 avoids damaging and costly employment tribunals or negative publicity

1 The Business of Diversity, Schneider-Ross (2002)

2 Measuring Leadership Effectiveness for Improved Organisational Performance: ASR Research (2004)

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3 What should we monitor?

3.1 We want to be confident that we understand the composition of our workforce, to take advantage of the benefits that a diverse workforce offers both the employee and the organisation.

3.2 The Civil Service diversity strategy, ‘Promoting Equality, Valuing Diversity’, sets out a

long term aim for each department and agency to know the disability status and ethnic background of at least 90% of their workforce and the religion or belief and sexual orientation of at least 80% of their workforce by the end of 2013. Departments and their agencies should by now have in place mechanisms to collect data on religion or belief and sexual orientation.

3.3 This guidance is designed to help departments and agencies to do this in a

consistent way, to allow for greater comparison and the sharing of good practice. Equality and diversity monitoring data should be collected on:

Age

Disability

Marriage/civil partnership status

Pregnancy and maternity

Race

Religion/belief

Sex

Sexual orientation

3.4 In addition, whilst there is no legal requirement to monitor the following categories, they are suggested as good practice, in support of the Government’s ambition to extend flexible working to all employees:

Caring responsibilities

Flexible working

Working Pattern (i.e. full-time or part-time)

3.5 This data needs to be analysed and used at various stages of the employment cycle including recruitment, training, performance appraisals, promotion, staff surveys, grievances and dismissals. It is also important that the data is kept up to date as, for example, disability status can change over time.

3.6 The Civil Service does not monitor gender identity. Instead, departments and

agencies should consider other approaches, such as specific initiatives to meet different needs of transsexual people, in order to measure progress on trans equality. However, questions in the Civil Service People Survey on the causes of discrimination, bullying and harassment in anonymous staff surveys do include ‘gender reassignment’ or ‘perceived gender’ as one of the possible causes.

3.7 It is important to note that section 22 of the Gender Recognition Act 2004 prohibits

disclosure of an individual’s gender identity who is protected by the Act.

The ‘prefer not to say’ option 3.8 Whether a department uses the category ‘prefer not to say’ is a matter for that

department to decide.

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4 What questions should we ask? 4.1 The following question recommendations are a combination of those categories used by the Office for National Statistics (ONS) (and their counterpart organisations) in the 2011 Census for England, Wales, Scotland and Northern Ireland, plus examples of best practice as promoted by external diversity organisations such as Stonewall, the Employers Forum on Disability and Opportunity Now. 4.2 If departments and agencies are using electronic media to collect this information they should ensure that those completing the questionnaire are able to move through to later questions if they do not wish to answer a certain question.

4.3 More detailed guidance on how to monitor within the various categories follows.

Case Study The Home Office’s approach to diversity and equality declaration Since 2007, the Home Office has collected diversity information on staff in respect of gender, ethnicity, disability, sexual orientation, religion and belief, age, grade and working pattern. In summer 2007, a new online Oracle-based system was introduced in the Home Office headquarters and the UK Border Agency so that staff could securely input their data online. This allowed staff to enter and update their own personal details, including the diversity data fields.

March 2008 March 2011

Ethnicity 60% 99%

Disability 79% 99%

Sexual orientation 29% 98%

Religion and belief 31% 98%

However, it was only when it became mandatory* for staff (in June 2008) to complete their diversity data in order to see their online payslips, together with a concerted communication campaign about the reasons for monitoring, that month on month, the department saw a significant increase in declaration that enable the Department to reach such high levels of declaration. In 2011, the department also added the categories of caring responsibilities and flexible working arrangements, plus a breakdown of disability status (e.g. manual dexterity or mobility) to better understanding these aspects of the Home Office workforce.

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Age

4.4 At the very minimum the age categories that should be used are:

16-24

25-29

30-34

35-39

40-44

45-49

50-54

55-59

60-64

65+

Prefer not to say

4.5 Adoption of these categories will allow for greater consistency and comparability across the Civil Service.

Caring responsibilities

4.6 Monitoring of staff caring responsibilities is not required by law but suggested as good practice.

4.7 There are 6 million carers in the United Kingdom and nearly one in eight workers are carers. With an ageing population and an expected increase of 60% of carers in the next 30 years, it is advisable to start monitoring the impact of policies on staff with caring responsibilities as they make up a sizeable proportion of the workforce. The question should read:

Do you have caring responsibilities? If yes please tick all that apply.

None

Primary carer of a child/children (under 18)

Primary carer of disabled child/children

Primary carer of disabled adult (18 and over)

Primary carer of older person/people (65 and over)

Secondary carer

Prefer not to say

Disability

4.8 To establish robust data on disability it is essential to develop a shared understanding of what having a disability means and to provide people with reassurance that their personal information is protected, will remain confidential and will not be used to their detriment.

4.9 There has been ongoing debate about the approach to defining disability and in relation to the medical and social models of disability in particular. Historically, the medical model has been the predominant way of thinking about disability, where the individual is defined by their condition. It is the condition that is likely to be perceived

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as the problem. The social model of disability, has now become the more acceptable way of thinking about disabled people. Here, it is the barriers in the environment such as stairs without ramps or lifts, non-inclusive or discriminatory policies, procedures or practices and people’s attitudes which actually ‘disable’ people.

4.10 Section 6(1) of the Equality Act 2010 states that a person has a disability if:

(a) That person has a physical or mental impairment, and (b) The impairment has a substantial and long-term adverse effect on that

person’s ability to carry out normal day-to-day activities.

4.11 In developing good quality data on disability, it is essential that disabled staff, in particular, are confident and satisfied that we handle the data in a sensitive, positive and appropriate way.

4.12 The above notes (or something similar) should be included as a guidance sheet in your monitoring information. Below is an example of how you might word your disability question:

Do you consider yourself to be disabled?

Yes

No

Prefer not to say

4.13 If you are an organisation which already has high levels of declaration on disability, and you would like to understand the differential impact on staff, you may wish to monitor the following, more detailed categories, suggested by the Employers Forum on Disability:

None

Hearing impairment

Mental ill health

Visual impairment

Mobility

Manual dexterity

Progressive conditions

Learning difficulties (where a person learns in a different way i.e. someone who is dyslexic

Facial disfigurement

Speech impairment

Other

Prefer not to say 4.14 Consideration should be given to regular reviews of the data collected, preferably annually, particularly to recognise the possibility of disability status changing.

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Enquiries about disability and health 4.15 Section 60 of the Equality Act 2010 states that an employer cannot ask applicants about their health before any selection process for a post, although collecting data for the purposes of monitoring is allowed.

4.16 Whilst not law, paragraphs 197-201 of the current Explanatory Memorandum to the Equality Act 2010 provides the following guidance: “197. Except in the situations specified in this section, an employer must not ask about a job

applicant’s health until that person has been either offered a job (on a conditional or

unconditional basis) or been included in a pool of successful candidates to be offered a job when a

suitable position arises. The specified situations where health-related enquiries can be made are for

the purposes of:

finding out whether a job applicant would be able to participate in an assessment to test his or her

suitability for the work;

making reasonable adjustments to enable the disabled person to participate in the recruitment process;

finding out whether a job applicant would be able to undertake a function that is intrinsic to the job, with

reasonable adjustments in place as required;

monitoring diversity in applications for jobs;

supporting positive action in employment for disabled people; and

enabling an employer to identify suitable candidates for a job where there is an occupational

requirement for the person to be disabled.

198. The section also allows questions to be asked where they are needed in the context of

national security vetting.

199. Where an employer makes a health or disability-related enquiry which falls outside the

specified situations, he or she would be acting unlawfully under the Equality Act 2006.

Together with Schedule 26, this section gives the Equality and Human Rights Commission

(EHRC) an enforcement role. (Section 120(8) ensures that only the EHRC can enforce a

breach of this provision.). This means, for example, that the EHRC would be able to

conduct an investigation if there was evidence that a large employer might be routinely asking

prohibited questions when recruiting.

200. Where the employer asks a question not allowed by this section and rejects the applicant, if

the applicant then makes a claim to the employment tribunal for direct disability discrimination,

it will be for the employer to show that it had not discriminated against the candidate.

201. As well as applying to recruitment to employment, the section also applies to the other

areas covered by Part 5 of the Act, such as

the other areas covered by Part 5 of the Act, such as contract work, business partnerships,

office-holders, barristers and advocates.”

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Race 4.17 Race, under the Equality Act 2010, includes colour, nationality, ethnic or national origins. Departments should explore mechanisms to record the nationality and or national identity of its workforce. Please note that nationality and national identity can differ, for example a member of staff who has a Scottish national identity would have British nationality. National identity 4.18 The ‘national identity’ categories in the 2011 censuses for ‘England and Wales’ and Scotland used different categories to those used in the 2011 census for Northern Ireland. Adding ‘prefer not to say’, these are:

England and Wales, and Scotland 2011 censuses

Northern Ireland 2011 census

British British

English English

Northern Irish Irish

Scottish Northern Irish

Welsh Scottish

Other Welsh

Prefer not to say Other

Prefer not to say

4.19 Departments and their agencies may wish to add all national identities particularly where there are staff overseas, like FCO and UK Border Agency (UKBA). A list of nationalities currently used by UKBA can be found at Annex B. 4.20 If a question on Nationality is used it should appear immediately before any question on ethnicity. ONS testing of the national identity question showed that British-born people from ethnic minority groups were more likely to answer the ethnic group question if a national identity question was asked first, as it allowed them to state that they were British Ethnicity 4.21 The Civil Service should follow the ethnicity classifications set out by ONS and their equivalent bodies for the 2011 Census for England, Wales, Scotland and Northern Ireland and should attempt by colour outside of this framework. The overall groupings are listed in the first column and the sub-categories are listed in the second column.

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Aggregate heading Categories for data collection

Notes

White English

Welsh

Scottish

Northern Irish

Irish

Gypsy or Irish Traveller

Polish Only required if you have staff in Scotland

Other white background

Mixed/multiple ethnic groups White and Black Caribbean

White and Black African

White and Asian

Any other mixed background

Asian/Asian British Indian

Pakistani

Bangladeshi

Chinese

Any other Asian background

Black/ African/ Caribbean/ Black British African

Caribbean

Any other Black/African/Caribbean background

Black, Black Scottish or Black British

Only required if you have staff in Scotland

Other ethnic group Arab

Any other ethnic group

Prefer not to say

If departments wish to add additional categories, they should be explicit about how these can be collapsed in order to allow comparison with the Census data.

Flexible working 4.22 This is not required by law but is recommended as good practice.

4.23 In consultation with Opportunity Now, the campaign organisation for gender equality in the workplace, the following should be monitored on flexible working. This is in addition to working pattern, as someone may be part-time but also working flexible hours or a homeworker, for example.

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4.24 If you wish to monitor this area, you should ask:

What is your current flexible working arrangement?

None

Flexi-time

Staggered hours

Term-time hours

Annualised hours

Job-share

Flexible shifts

Compressed hours

Homeworking

Other

Prefer not to say Gender Identity 4.25 As an equal opportunities employer, the Civil Service is committed to delivery of a working environment free from prejudice and unlawful discrimination, and that, of course, includes on grounds of gender reassignment. The new Public Sector Equality Duty now provides greater protection for transsexual people.

4.26 Section 22 of the Gender Recognition Act 2004 prohibits employers from making known the gender of an individual who is protected by the Act. This carries criminal sanctions and for this reason, we do not collect data on the gender identity of our staff. However, in terms of paying due regard (as required by the Equality Act 2010) to gender identity, consideration should be given as to how individuals who live in, or identify with a gender which differs from the birth will be impacted on. Gender identity considerations during restructuring 4.27 In the context of restructuring/reducing a part of the business where staff will be made surplus, it is important that whilst no data on gender identity is collected, the impact in relation to gender identity is still considered. Where a line manager is aware that a member of their staff will be, or is undergoing or has undergone the process of gender reassignment, the line manager should maintain the confidentiality of the individual concerned. As well as the Data Protection Act and Human Rights Act some will have additional privacy protection afforded under the Gender Recognition Act and best practice is to treat all as if they have such recognition. Gender reassignment is a protected characteristic under the Equality Act 2010.

4.28 However, they should take steps to ensure the needs of the individual are appropriately taken into consideration when taking into account the restructuring and redundancy policy. Where necessary, consent and involvement of the individual member of staff should be sought throughout the restructuring and redundancy policy implementation, to satisfy them that all steps are being taken not to compromise their right to privacy.

4.29 On occasions, individuals may willingly give their consent to declaration on their gender identity. No individual should be pressured into giving such consent.

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However as a safeguard for all concerned, when such consent is given, it should be in writing.

4.30 In addition, it is necessary to ensure that staff who are protected under the Equality Act is given due consideration in terms of avoiding discriminatory actions in all situations within the workplace and not just in relation to restructuring or redundancy exercises, though this is also clearly important. Marriage/Civil Partnership Status

4.31 ‘Marital/civil partnership status’ can be included as this is included in section 8 of the Equality Act 2010 and part of the Public Sector Equality Duty in respect of the requirement to have due regard to the need to eliminate discrimination. The category ‘married’ should not be separate to ‘Civil Partnership’ but as one category. Therefore, the question should be:

Are you married or in a civil partnership?

Yes

No

Prefer not to say

Pregnancy and Maternity 4.32 Departments and their agencies should have in place adequate mechanisms for monitoring women who are pregnant or on maternity leave to ensure that they are not subject to unfavourable treatment in employment. Areas that departments should pay particular attention to would include monitoring in restructuring, recruitment, promotion, bullying and harassment, pay and reward and sickness absence. It is also crucial that situations involving redundancy are monitored closely, particularly since there are specific provisions within the law that women on maternity leave should be offered a suitable alternative vacancy. 4.33 A woman is protected under section 18 of the Equality Act 2010 and cannot be treated unfavourably because of the pregnancy or because of illness suffered by her as a result of it, or because she is on compulsory maternity leave, or she is exercising or seeking to exercise, or has exercised to sought to exercise, the right to ordinary or additional maternity leave. Monitoring should take place in key employment processes for any evidence of unfavourable treatment. The department should ask In those scenarios, the question should be:

As a woman, are you pregnant, on maternity leave or returning from maternity leave?

Yes

No

Prefer not to say 4.34 Monitoring in this area may show small sizes and it may be difficult to draw any statistical conclusions from those samples. As such, departments may wish to take this into account before deciding to create a specific data capture capability.

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Religion/belief

4.35 The 2011 Census categories on religion and belief differ for England, Wales, Scotland and Northern Ireland. The question and categories should be:

What is your religion or belief?

No religion

Christian (including Church of England, Catholic, Protestant and all other Christian denominations)

Buddhist

Hindu

Jewish

Muslim

Sikh

Any other religion

Church of Scotland Only required if you have staff in Scotland

Roman Catholic Only required if you have staff in Scotland and Northern Ireland

Presbyterian Church in Ireland Only required if you have staff in Northern Ireland

Church of Ireland Only required if you have staff in Northern Ireland

Methodist Church in Ireland Only required if you have staff in Northern Ireland

Prefer not to say

4.36 If departmental systems allow, good practice suggest that the following categories could also be added:

Agnostic Atheist Bahai Humanism Jain Pagan Rastafarian Scientologist Shinto Zoroastrian

Sex 4.37 ‘Male’ and ‘female’ are the only two genders recognised in law. Please note that in no circumstance should a third category of ‘Other’ be included as this can be offensive to those who are intersex or who have changed gender. Therefore, the categories should be:

Male

Female

Sexual orientation 4.38 As identified as best practice from Stonewall, the recommended question and categories are:

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What is your sexual orientation?

Heterosexual/straight

Gay woman/lesbian

Gay man

Bisexual

Other

Prefer not to say

4.39 ONS testing has shown that in order to improve the accuracy of responses the question on sexual orientation should feature before that on religion. They found that if the question on religion preceded that on sexual orientation it adversely impacted the sexual orientation response. Working pattern

4.40 Whilst not required by law, this is recommended as good practice. This would be in addition to the categories on flexible working and should be:

What is your working pattern?

Full-time Part-time Prefer not to say

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5 Preparing the organisation for monitoring

5.1 Monitoring equality and diversity will only be successful if all staff support the

initiative, including those from majority groups. Proportions of staff from particular groups, such as disabled staff, or staff from ethnic minority backgrounds, are always expressed as a proportion of those whose disability status or ethnic background is known. Unless staff who are not disabled and who are in majority ethnic groups also participate in monitoring, the resulting data for under-represented groups will not be robust. A strong case for monitoring, with clearly detailed aims and benefits (see Chapter 2) and outcomes for the organisation is an essential tool for gaining this support.

5.2 The principles in this section for laying the groundwork to achieve support for

monitoring builds on the existing good practice across the Civil Service. 5.3 Experience shows that confidence in any drive to improve declaration will be

enhanced if senior managers and Board members are known to be taking part, or have already completed their equality information.

5.4 It is important to involve and consult with key stakeholders. This will enable

compilation of monitoring information and communications that are tailored to the needs and expectations of individual departments and agencies. It is important to gain support from key stakeholders, to pre-empt any barriers to declaration and to find an effective way to promote the initiative within the organisation.

5.5 Key stakeholders to consider involving and consulting with include:

All staff;

Line managers;

Senior management;

Trade Unions;

Staff support network groups;

Internal communication specialists; and

Other identified stakeholders that could impact on the success of the initiative.

5.6 The support of these key individuals and groups can help to secure the

participation of employees. Communication 5.7 All staff must be made fully aware of what they are expected to do and why.

They must be reassured that the organisation’s prime motivation in carrying out the monitoring exercise is to establish equality of opportunity for every employee, enabling everyone to contribute to their full potential.

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5.8 The monitoring initiative must be widely and carefully communicated. Experience has shown that best results are achieved where communications are made jointly with the trade union side. This could be done via a number of channels including:

Top management messages of communication

Personal emails

Intranet pages

Internal newsletters

Team briefings

Posters

Launch events

5.9 In any communication it is important to stress exactly why the information is

needed and communicate the benefits of collecting and using this information. Assurances must be given about confidentiality and on how the information will be stored and used, and on who will have access to this information.

5.10 Prior to any staff communication it is important to ensure that key

stakeholders such as heads of business units and HR Business Partners are

Case Study Diversity monitoring in the Department of Health In July 2009, the Department of Health launched its diversity monitoring exercise through the Permanent Secretary's monthly update, Managers' briefing and a front-page story on the intranet. The aim being to update the existing employee data on disability and ethnicity using the census classifications; and to extend monitoring to sexual orientation, religion or belief and caring responsibilities. The first stage of the exercise was an on-line completion via the HR self-service facility. The second stage involved a paper-based exercise after which those that had not made a declaration were followed up by phone. Four months on, the Department achieved declaration rates of 95% on Disability and 96% on Ethnicity and around 60% for the other three new categories. We believe that the successful outcome of the exercise was due to;

a comprehensive communication strategy;

the involvement of stakeholders (including Unions and staff networks) from an early stage; and

the paper-based follow-up – which was the most productive method used. The paper-based exercise only required staff to tick a few boxes and return in a self-addressed envelope provided. The response rate was higher than the telephone follow-up. The communication strategy included a note from the HR Director outlining the aims and benefits of the exercise, attached to the note was a ‘Question and Answer’ brief covering all aspect of the exercise from ‘how the categories were developed’ to ‘what the data would be used for’.

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made aware of any impending declaration exercise so that they can proactively support the drive to improve declaration.

5.11 Throughout any drive to improve declaration it is essential that staff receive

messages encouraging them to complete and to update their equality and diversity information through both formal channels such as the intranet and staff magazines and through informal channels via contact with their managers and their HR Business Partners. Trade unions and staff networks can also play a useful role in emphasising the positive aspects of monitoring.

5.12 Improving declaration is an ongoing process. It is therefore vital to build upon any previous drive to improve declaration. This may be done by focussing on those that have not made a declaration and contacting them confidentially either via telephone or email.

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6 Use of diversity data

Once this data has been collected it is vital for it to be used, and for it to be seen to be used. Demonstrating its value and use will encourage further declaration. For example, during the recruitment cycle, by collecting and then analysing the data at various stages you can see which groups have applied for vacancies and see whether or not they have, proportionately, made it through the initial sift, interview and then through to final selection. This initial analysis may then be followed by some qualitative research on the barriers which may have existed for any groups disproportionately represented at any particular stage, followed up by an appropriate action to remove any unfair barriers.

Using equality information to set representation benchmarks 7.6 When setting achievable representation targets benchmarks, departments should consider all relevant data available to them. They should pay particular attention to historical and projected trends on flows into, out of and within the SCS by the different diversity groups and to the relevant populations that feed into the SCS e.g. number of women at Grade 6 and 7. In addition, departments may also wish to take into account any activity on talent management such as the nine-box system, future vacancies and any succession/workforce plans that may have been developed. 7.7 This information should be used to set achievable benchmarks and track progress.

Stage 1 – This is the first cut of data by protected characteristic which may show, for example, that women are leaving the department at greater rates than men.

Stage 3 – Where issues are identified, departments may wish to run targeted surveys and focus groups with staff to get quantitative and qualitative feedback so that appropriate interventions could be put in place.

Stage 2 – The next level of analysis might be to look across multiple protected characteristics to see if there are patterns which better explain the first cut of data. For example, departments may look at women who work part-time leaving the organisation.

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Case Study ONS use of data to monitor and set its Equality and Diversity Objectives In 2008/9 ONS recognised the need for a high level management tool which would bring together a range of equality and diversity data to enhance its ability to understand the experience of protected groups in ONS, to identify any issues that may exist and to prioritise which issues needed to be tackled. ONS developed an Equality and Diversity Dashboard (based on a draft template created by the Civil Service Data Monitoring Group which now does not exist). This Dashboard brings together information on:

progress against its SCS and feeder grade targets for gender, ethnicity and disability

staff profile by grade across the protected characteristics

staff declaration rates for each protected characteristic

information from its HR Data Monitoring process for performance management; promotion; recruitment; grievance and training for each protected characteristic

People Survey data across the protected characteristics

a simple RAG status to identify progress This dashboard has, for the past two years, been discussed by the ONS Equality and Diversity Steering Group, to identify and monitor priority areas for action for the coming twelve months. The dashboard is shared widely across the business. ONS staff network groups are asked to feed into the development of action plans and make recommendations on the way forward. Its current priority areas have remained the same for 2011 and 2012:

Disability

Representation of women at SCS

Part Time working This has resulted in action plans for each group. Although it is still too early to see the medium term effects of these action plans, ONS has noticed an increase in its employment engagement index for its disabled staff in its most recent People Survey. The diversity dashboard forms a significant part of the ONS Equality and Diversity Report, which is published on its website. A link to the latest report which includes the Diversity Dashboard is available here: http://www.ons.gov.uk/ons/about-ons/who-we-are/about-diversity/how-we-measure-equality-and-diversity/index.html

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Annex A – Sample Equal Opportunities Monitoring Form

The [Department] is committed to recruiting, retaining and developing a workforce that reflects at all grades the diverse communities that we serve. It is vital that we monitor and analyse diversity information so that we can ensure that our HR processes are fair, transparent, promote equality of opportunity for all staff, and do not have an adverse impact on any particular group. Your cooperation in providing us with accurate data will ensure that we, not only meet our legal obligations, but even more importantly will result in us designing and applying policies and processes that attract and retain a diverse, talented and motivated workforce. Any information provided on this form will be treated as strictly confidential and will be used for statistical purposes only. It will not be seen by anybody directly involved in the selection process. No information will be published or used in any way which allows any individual to be identified.

Gender Male Female

Are you married or in a civil partnership Yes No

Age 16-24 25-29 30-34 35-39 40-44 45-49 50-54 55-59 60-64 65+ Prefer not to say

How would you describe your national identity?

English Welsh Scottish Northern Irish

British Other Prefer not to say

What is your ethnicity? Ethnic origin categories are not about nationality, place of birth or citizenship. They are about the group to which you as an individual perceive you belong. Please indicate your ethnic origin by ticking the appropriate box White

English Welsh Scottish Northern Irish

Irish Gypsy or Irish Traveller Other White background Mixed/multiple ethnic groups

White and Black Caribbean White and Black African

White and Asian Any other mixed background

Asian/Asian British

Indian Pakistani

Bangladeshi Chinese

Any other Asian background Black/ African/ Caribbean/ Black British

African Caribbean

Any other Black/African/Caribbean background Other ethnic group

Arab Any other ethnic group Prefer not to say

23

Do you consider yourself to be disabled? Yes No Prefer not to say Any information you provide here will be used for monitoring purposes only – if you need a ‘reasonable adjustment’, then please follow the additional separate process. We will take reasonable steps to meet your particular needs.

What is your sexual orientation?

Heterosexual/straight Gay woman/lesbian

Gay man Bisexual

Other Prefer not to say

What is your religion or belief?

No religion Buddhist Christian

Hindu Jewish Muslim

Sikh Any other religion Prefer not to say

What is your current working pattern?

Full-time Part-time Prefer not to say

What is your flexible working arrangement?

None Flexi-time

Staggered hours Term-time hours

Annualised hours Job-share

Flexible shifts Compressed hours

Homeworking Other

Do you have caring responsibilities? If yes please tick all that apply

None

Primary carer of a child/children (under 18) Primary carer of disabled child/children

Primary carer of disabled adult (18 and over) Primary carer of older person (65+)

Secondary carer Prefer not to say

By completing this form you have helped us better understand how we, as an employer, ensure equality of opportunity for all.

Thank you for completing this form.

24

Annex B - NATIONALITY CODES (as used by the UK Border Agency)

AFGHANISTAN AFG

ALBANIA ALB

ALGERIA DZA

AMERICA USA

AMERICAN SAMOA ASM

ANDORRA AND

ANGOLA AGO

ANGUILLA AIA

ANTARCTICA (BRITISH) ZZZ

ANTIGUA AND BARBUDA ATG

ARGENTINA ARG

ARMENIA ARM

ARUBA NLD

AUSTRALIA AUS

AUSTRIA AUT

AZERBAIJAN AZE

BAHAMAS BHS

BAHRAIN BHR

BANGLADESH BGD

BARBADOS BRB

BARBUDA ATG

BELARUS BLR

BELGUIM BEL

BELIZE BLZ

BENIN BEN

BERMUDA BMU

BHUTAN BTN

BOLIVIA BOL

BOSNIA-HERZOGOVINA BIH

BOTSWANA BWA

BOUVET ISLAND NOR

BRAZIL BRA

BRITISH CITIZEN GBR

BRITISH DEPENDENT TERRITORIES CITIZEN

- (TERRITORY NOT KNOWN) GBD

BRITISH NATIONAL (OVERSEAS) GBN

BRITISH OVERSEAS CITIZEN GBO

BRITISH PROTECTED CITIZEN GBP

BRITISH INDIAN OCEAN TERRITORIES IOT

BRITISH SUBJECT GBS

BRUNEI DARUSSALAM BRN

BULGARIA BGR

BURKINO FASO BFA

BURMA (MYANMAR) MMR

BURUNDI BDI

CAMBODIA (KAMPUCHIA) KHM

CAMEROON CMR

CANADA CAN

CAPE VERDE CPV

CAYMAN ISLANDS CYM

CENTRAL AFRICAN REPUBLIC CAF

CHAD TCD

CHILE CHL

CHINA PEOPLES REP, OF CHN

CHINA REP. OF (TAIWAN) TWN

CHINA, SPECIAL ADMINISTRATIVE REGION (Hong Kong)

-HOLDER OF HKSAR PASSPORT HKG

-BN (O) GBN

-HOLDER OF CI OR DI XXH

-CATEGORY UNKNOWN HKG

CHRISTMAS ISLANDS AUS

COCOS (KEELING) ISLANDS AUS

COLOMBIA COL

COMOROS COM

CONGO COG

CONGO DEMOCRATIC REPUBLIC ZAR

COOK ISLAND NZL

COSTA RICA CRI

COTE d'Ivoire CIV

CROATIA HRV

CUBA CUB

CYPRUS CYP

CYPRUS (TURKISH REP. OF NORTHERN CYPRUS)

XXT

CZECH REPUBLIC CZE

CZECHOSLOVAKIA CSK

DENMARK DNK

DJIBOUTI DJI

DOMINICA DMA

DOMINICAN REPUBLIC DOM

EAST TIMOR IDN

ECUADOR ECU

EGYPT EGY

EL SALVADOR SLV

EQUATORIAL GUINEA GNQ

ERITREA ERI

ESTONIA EST

ETHIOPIA ETH

FALKLAND ISLANDS FLK

FAROE ISLANDS FRO

FIJI FJI

FINLAND FIN

FRANCE FRA

FRENCH GUIANA FRA

FRENCH POLYNESIA FRA

FRENCH SOUTHERN TERRITORIES FRA

GABON GAB

GAMBIA GMB

GEORGIA GEO

25

GERMANY D

GHANA GHA

GIBRALTAR GIB

GREECE GRC

GREENLAND GRL

GRENADA GRD

GUADELOUPE FRA

GUAM USA

GUATEMALA GTM

GUINEA GIN

GUINEA-BISSAU (REP. OF) GNB

GUYANA GUY

HAITI HTI

HEARD AND MCDONALD ISLANDS AUS

HOLY See (VATICAN) VAT

HONDURAS HND

HONG KONG, SPECIAL ADMINISTRATIVE REGION OF CHINA

-HOLDER OF HKSAR PASSPORT HKG

-BN (O) GBN

-HOLDER OF CI OR DI XXH

-CATEGORY UNKNOWN HKG

HUNGARY HUN

ICELAND ISL

INDIA IND

INDONESIA IDN

IRAN IRN

IRAQ IRQ

IRELAND IRL

ISRAEL ISR

ISRAELI OCCUPIED TERRITORIES

- NON NATIONAL DOCUMENT XXP

ITALY ITA

IVORY COAST CIV

JAMAICA JAM

JAPAN JPN

JORDAN JOR

KAMPUCHEA KHM

KAZAKHSTAN KAZ

KENYA KEN

KIRIBATI KIR

KOREA DPR (N. KOREA) PRK

KOREA REP OF (S. KOREA) KOR

KUWAIT KWT

KYRGYZSTAN KGZ

LAOS LAO

LATVIA LVA

LEBANON LBN

LESOTHO LSO

LIBERIA LBR

LIBYA (ARAB REPUBLIC) LBY

LIECHTENSTEIN LIE

LITHUANIA LTU

LUXEMBOURG LUX

MACAO (1)

MAC

MACEDONIA MKD

MADAGASCAR (MALAGASY REP.) MDG

MALAWI MWI

MALAYSIA MYS

MALDIVES MDV

MALI MLI

MALTA MLT

MARSHALL ISLAND MHL

MARTINQUE FRA

MAURITANIA MRT

MAURITIUS MUS

MAYOTTE FRA

MEXICO MEX

MICRONESIA FSM

MOLDOVA, REPUBLIC OF MOA

MONACO MCO

MONGOLIA MNG

MONTENEGRO YUG

MONTSERRAT MSR

MOROCCO MAR

MOZAMBIQUE MOZ

MYANMAR (BURMA) MMR

NAMIBIA NAM

NATIONALITY UNKNOWN - OFFICIALLY

DESIGNATED AS SUCH (2)

XXX

NATIONALITY UNKNOWN - OTHER (all systems except SI)

ZZZ

NATIONALITY UNKNOWN - OTHER (Suspect Index)

blank

NAURU NRU

NEPAL NPL

NETHERLANDS NLD

NETHERLANDS ANTILLES NLD

NEW CALEDONIA FRA

NEW HEBRIDES (VANUATU) VUT

NEW ZEALAND NZL

NICARAGUA NIC

NIGER NER

NIGERIA NGA

NIUE NIU

NORFOLK ISLAND AUS

NORTH KOREA PRK

NORTHERN MARIANA ISLANDS USA

NORWAY NOR

OMAN OMN

PAKISTAN PAK

PALAU PLW

PALESTINE PSE

PANAMA PAN

PAPUA NEW GUINEA PNG

PARAGUAY PRY

26

PERU PER

PHILIPPINES PHL

PITCAIRN ISLANDS PCN

POLAND POL

PORTUGAL PRT

PUERTO RICO USA

QATAR QAT

REUNION FRA

ROMANIA ROM

RUSSIA RUS

RWANDA, REP OF RWA

ST. HELENA SHN

ST. KITTS AND ST. NEVIS KNA

ST.LUCIA LCA

ST. PIERRE AND MIQUELON FRA

ST. VINCENT AND THE GRENADINES VCT

SAMOA (WESTERN SAMOA) WSM

SAN MARINO SMR

SAO TOME AND PRINCIPE STP

SAUDI ARABIA SAU

SENEGAL SEN

SERBIA YUG

SEYCHELLES SYC

SIERRA LEONE SLE

SINGAPORE SGP

SLOVAKIA SVK

SLOVENIA SVN

SOLOMON ISLANDS SLB

SOMALIA SOM

SOUTH AFRICA ZAF

SOUTH Georgia AND THE SOUTH SANDWICH ISLANDS

FLK

SOUTH KOREA KOR

SOVIET UNION (USSR) SUN

SPAIN ESP

SRI LANKA LKA

STATELESS - AS DEFINED IN 1954 CONVENTION

(3)

XXA

STATELESS REFUGEE - AS DEFINED IN 1951 CONVENTION

(3)

XXB

STATELESS REFUGEE - OTHER (3)

XXC

SUDAN SDN

SURINAM SUR

SVALBARD AND JAN MAYEN ISLANDS NOR

SWAZILAND SWZ

SWEDEN SWE

SWITZERLAND CHE

SYRIA SYR

TAIWAN TWN

TAJIKISTAN TJK

TANZANIA TZA

THAILAND THA

TOGO TGO

TOKELAU NZL

TONGA TON

TRINIDAD AND TOBAGO TTO

TUNISIA TUN

TURKEY TUR

TURKISH REPUBLIC OF NORTHERN CYPRUS (TRNC)

XXT

TURMENISTAN TKM

TURKS AND CAICOS ISLANDS TCA

TUVALU TUV

UGANDA UGA

UKRAINE (UKRANIAN SSR) UKR

UNION OF MYANMAR (BURMA) MMR

UNITED ARAB EMIRATES ARE

UNITED KINGDOM GBR

UNITED NATIONS - SPECIALIZED AGENCY

UNA

UNITED NATIONS - OTHER UNO

UNITED STATES OF AMERICA USA

UNITED STATES MINOR OUTLYING ISLANDS

USA

UPPER VOLTA (BURKINA FASO) BFA

URUGUAY URY

USSR SUN

UZBEKISTAN UZB

VANUATU (NEW HEBRIDES) VUT

VATICAN (HOLY SEE) VAT

VENEZUELA VEN

VIETNAM VNM

VIRGIN ISLANDS (BRITISH) VGB

VIRGIN ISLANDS (U.S.) USA

WALLIS FUTUNA ISLANDS FRA

WESTERN SAHARA (PROVISIONAL NAME)

ZZZ

WESTERN SAMOA (SAMOA) WSM

YEMEN YEM

YUGOSLAVIA YUG

ZAIRE (CONGO DEMOCRATIC REPUBLIC)

ZAR

ZAMBIA ZMB

ZIMBABWE ZWE